SSOs & FOG ControlAdvanced 24 min read

SSOs & FOG Control: FOG Ordinance Design & Capacity Assurance Planning

Advanced program-management content on building a FOG control ordinance from pretreatment legal authority, designing a defensible enforcement program, running capacity assurance planning as a CMOM core area, and integrating both into overall NPDES/CMOM compliance.

A FOG control program only has teeth if it's built on real legal authority, designed to be defensible when enforcement escalates to fines or legal action, and connected to a forward-looking view of whether your system has the capacity to handle the flows it's already carrying — let alone the growth coming next year. This guide covers building a FOG ordinance from the ground up, running the enforcement program behind it, and the capacity assurance planning process that ties directly back into your utility's capital program and CMOM performance.

Legal Authority: Building a FOG Control Ordinance

Where the authority comes from. The Clean Water Act's pretreatment program, implemented through 40 CFR Part 403 (General Pretreatment Regulations for Existing and New Sources of Pollution), gives publicly owned treatment works (POTWs) the authority to control what indirect dischargers —

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